BRIGHT, Circuit Judge.
In this action, Land O'Lakes, a cooperative corporation, seeks a refund of income taxes in the sum of $254,978.74 (including interest) which it paid under a deficiency assessment for the year 1963. This deficiency arose because the Government revoked Land O'Lakes' status as an exempt farmers' cooperative under § 521 of the Internal Revenue Code, 26 U.S.C. § 521 (1970), for its operations during calendar year 1963. The district court...
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